Making Europe’s economy circular: the time is nowSam
By Tudy Bernier, Senior Policy Manager, UNESDA
We are enthused to have sight of the Commission’s much anticipated Circular Economy Action Plan. The circular economy lies at the very heart of the Commission’s new regenerative growth strategy for Europe and UNESDA is fully committed to supporting the transition. As we embark on this next phase of Europe’s Circular Economy strategy, our industry needs three things: legal certainty, a long-term vision and a holistic approach, working in partnership with all actors. We need to create efficient collection schemes to increase collection of all beverage containers to ensure the availability of high quality rPET and continue to recycle aluminium and glass in a sustainable way. Only by doing this, can we guarantee a well-functioning internal market for secondary material.
Less waste, more valuable resources
The acknowledgment that Europe needs a step-change towards a circular model where waste is turned into a valuable, secondary raw material, is music to our ears. Making our packaging more circular and sustainable is a core priority. We need to create efficient collection schemes to increase collection of all beverage containers to ensure the availability of high quality rPET and continue to recycle aluminium and glass in a sustainable way. Only by doing this, can we guarantee a well-functioning internal market for secondary material.
Many of our members – including Suntory, PepsiCo and Coca-Cola – have announced ambitious targets for sustainable, recycled content. They continue innovating to make all of our packaging sustainable – lightweighting aluminium cans to make them even more circular and introducing 100% rPET bottles onto the market.
In tackling packaging waste there are three things that matter: collection, collection, collection. We must ensure that the right infrastructures and technologies are in place and all stakeholders are playing their part to achieve higher collection targets while also reducing packaging through innovation and lightweighting.
We support both Deposit Return Schemes (DRS) for beverage packaging – which need to be introduced more widely across the EU wherever alternative systems fail to accelerate the transition towards a circular model; and Extended Producer Responsibility (EPR) schemes covering various packaging types and materials – which are already in place in a number of EU countries but need to be optimised. We welcome the Commission’s intention to take measures to improve the performance of EPR schemes – particularly on eco-modulating producer fees – and to examine how they could be applied to a wider range of products and included into producer ownership models. We call on the Commission to provide guidance to Member States for harmonisation of efficient collection schemes, such as DRS and EPR, in order to accelerate implementation timeframes. This includes ensuring that we limit free-riding and make sure that all actors contribute to the funding and running of schemes.
Recycling techniques are the next important step in the circular loop. Today’s highly efficient mechanical recycling schemes must be complemented by new, innovative technologies – including enhanced recycling. By combining the use of mechanically recycled PET, enhanced recycled PET and renewable PET, our industry can reduce its carbon footprint while delivering its products in a safe and sustainable packaging. Policymakers can empower the industry to deliver on its circularity objectives by supporting such innovation and the use of all available technologies. In practical terms, this means taking action to unleash recycling innovation by validating pending authorisations for mechanical recycling and providing a clear regulatory framework for enhanced recycling to allow all players to move to the next level.
Clarity and legal certainty are key
While there is much to get our teeth into and we welcome the creation of a sustainable product policy framework, we need more clarity in several areas. For example, the Commission states that it “will present a sustainable product policy framework applicable to raw materials, intermediate and consumer products by 2030”. We ask that particular attention be given to the definition of a “sustainable product” and how industry can help in delivering sustainably by 2030. Our industry has already taken significant steps – including committing that by 2025 100% of our plastic packaging will be recyclable and contain a minimum 25% recycled content. In parallel, under EU law, collection rates for plastic bottles must reach 90% by 2029 and several countries are already meeting those targets having introduced deposit return schemes. It would seem logical that a product that is entirely recyclable, uses recycled content and enters a highly efficient collection scheme, should be defined as sustainable. We urge the Commission to give due attention to such definitions in consultation with all relevant stakeholders.
A circular Europe must also be a competitive one. The transition means changing our production processes and investments to compete in the EU market and beyond. EU authorities must provide legal certainty as to which packaging formats are considered sustainable in order that producers can make the right investments and thus guarantee employment in the European internal market long term. They must also promote consistent policies and not send contradictory messages. This means avoiding measures that could hinder efforts to reduce carbon footprint or sending contradicting signals which could lead to the banning of products which are both recycled and use a high level of recycled content. For instance, we regret the decision of the French government to phase-out all SUP by 2040 as this could imply that circularity for certain products should not be pursued.
Empowering consumers as part of a multi-stakeholder approach
We are delighted to see European Commission policy carving out a role for the EU’s 450 million citizens in helping to create a circular economy. Our industry is part of the fabric of Europe’s economy and provides employment for some 1.7 million people up and down its value chain. We listen closely to what our consumers, employees and collaborators are telling us and know that they are enthusiastic to get involved.
We also note the Commission aims for consumers to have access to clearer information about the environmental aspect of products. We support a common, European approach to providing consumers with fact-based, fit-for-purpose information on the sustainability of food and drink products. A proliferation of different labels risks confusing people and we would welcome Commission action on environmental claims that ensures the proper calculation of a product’s environmental footprint.
Giving circularity a chance to deliver on environmental objectives
It’s time to consider waste as a true resource. As we transition to a cleaner, more competitive Europe, we will encounter new developments and innovations along the way. Opportunities such as alternative recycling methods and bio-based packaging options hold great potential and we must ensure that they are fully explored and not stifled.
Transitioning towards circularity also means providing all actors with a clear direction and roadmap, with no contradictions. Our sector is committed to making its packaging more sustainable and tackling plastic waste, and in doing so we need long-term visibility and assurance that we won’t see a ban on certain packaging per se, which would render our investments redundant.
As policymakers, economic players, consumers and citizens we are all travelling this journey together. The soft drinks industry is excited to work with all stakeholders in transitioning towards a new circular world.